2019 (8) TMI 738

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....ORAL ORDER (PER : HONOURABLE MR.JUSTICE J.B.PARDIWALA) 1 This Tax Appeal under Section 260A of the Income Tax Act, 1961 [for short, "the Act, 1961"] is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Surat Bench, Surat dated 28th September 2018 in the I.T.A. No.1006/AHD/2015/SRT for the assessment year 2006-07. 2 The Revenue ha....

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....w information came into possession subsequently. The perusal of the reasons recorded for reopening shows that the AO has not mentioned that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. Even the assessment order also makes no mention of such failure on the part of the assessment. It is also noticed that assessee has filed....

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....erment that the assessments are sought to be reopened by reason of failure on the part of assessee to disclose fully and truly all material facts necessary for assessment for the relevant assessment year, the very initiation of proceedings u/s.l47 by issuance of notice u/s.148 after expiry of four years from the end of relevant assessment year is bad and cannot be sustained. 7 In the ligh....